New White Space Issues

[ParkerAudio]

Hey all,

I just received this email from a colleague at CNBC.  On behalf of all us RF, Sound Dudes & Dudettes,  I want to thank Kevin Parrish and the technicians at NBC LIC for the hard work and this quick report! I've had the opportunity to work with these guys and they are true professionals.

Kevin Parker

Parker Audio, Inc.

Subject: White Space Device Causes RF Interference to Production Wireless Microphone Systems @ CTIA Show

TO UN-DISCLOSED RECIPIENTS:

I wanted to advise you on what may be one of the first reported cases of rf interference caused by a White Space Device (TVBD) operating at the CTIA Show in Orlando, Florida.

CNBC is an exhibitor at the 2011 CTIA Show and will originate several live remote-broadcasts from the show 3/22 thru 3/24.

We're operating 18 wireless microphone channels at the show and intended to utilize Lectrosonics BLOCK-25….

Well all was proceeding quite nicely until this afternoon when un-expectedly a very unusual type of interference popped-up on our receivers.  This rf interference was something that I had never seen before, it occupied 7 MHz in total bandwidth with multiple narrow carriers evenly spaced which then appeared to randomly move in frequency within BLOCK-25.

An NBC RF Engineer using mobile direction finding techniques quickly located the source of interference within the Orange County Florida Convention Center.

Further investigation revealed the source of the interfering signals to be emanating from an apparent "TVBD" White Spaces Device which was concealed inside a hallway corridor kiosk sign.

The "TVBD" equipment was positively identified as being "Airspace Micro-Max" which apparently is a next generation Wi-Fi / White Spaces Base Station that operated in this instance on frequencies from 656 - 663 MHz inside the Orange County Convention Centers, North Hall.

Manufacturer: Airspan

Model: ASMAX / MICRO-MAX 650M TDD EXT

          908-03-057-BO

FCC Type Acceptance Number:

http://site.airspan.com/products/micromax-micro-cell-wimax/

Professional Wireless Microphone users should be on the lookout for this type of equipment causing destructive interference to wireless microphones, IFBs, RFPLs  and related low-power broadcast auxiliary equipment !

Pay special attention to the frequency coordination efforts currently underway which have been mandated by the FCC in order to protect yourself and clients from TVBD interference.

Read the trade publications and manufacturers technical bulletins on this hot topic, stay informed, continue to educate yourself since we face many unknown issues as professional production wireless equipment users.

Kevin Parrish

[Philip Perkins]

So I'm trying to parse what this means for regular, working, ground-level production soundies, and this is what I'm thinking:  If there is an open TV channel in your area (one that you might have seen as open and bought some wireless gear to use), there is a chance that someone will park one of these devices on it, which they are allowed to do without notice or permission (the same way we use our radio mics).  Some diffs between a device like the one described and our wirelesses would be radiated power (they have much more), and the fact that the device seemed to be all over 2 TV channels, while we use a very small slice of spectrum per channel.  The radiated energy of this device sounds like it made the OP's wirelesses unusable on their chosen freqs, and that (impressively) was happening within a big concrete arena.  So....here we are with wireless RX that are only tunable over 3 adjacent blocks, and now there is the growing potential for these wifi RF bandwidth hogs to pop up anywhere.  I recall that there was originally going to be some kind of RF sensing  requirement for theses devices so they wouldn't run over other users, but I also recall that those sensing systems never worked in test, and they gave up on them and decided to just run us over anyway.  Another recollection: there was supposed to be a couple of TV channels worth of spectrum "reserved" for wireless mic use in each area (esp for big time users like the OP)--but I haven't seen an announcement of exactly what those freqs are in specific cities--has anyone else?  Or was that just another sop to calm down the whining wireless mic people, like the BS RF sensing systems they were talking about (ie, they aren't really going to reserve any space at all, they are going to park those things wherever they want to that isn't a DTV or etc freq already)?

I'd like to know more about this incident (and what the OP did about it).  The website for that device says that it can operate in various gigahertz bands and in the 700MHz band, but doesn't mention operation below 700 MHz.

feelin' great about my FCC,

phil p

[ParkerAudio]

Phil,

I think you hit it dead on. Rf sensing is gone, no reserved rf space for microphones ....etc .    The scariest part of this device was that the frequencies blindly moved around, making any frequency plan on the RF Tech's side useless.

If you haven't seen it already, here's a recent (scary) article.

http://www.usatoday.com/money/media/2011-03-24-fcc-tv-stations-broadcast-spectrum.htm

Looks like they are getting hungry for more.

Parker

[studiomprd]

this is not really new,  just evolutionary...

There have always been other sources of potential RF interference besides TV stations.

Like WiFi, these devices do some sensing and hopping, but what is truly scary is taht these are consumer devices, and the really vast numbers of these devices that will soon be out there...

[Philip Perkins]

I'll say it again: the makers of wireless mic equipment need to find a technical solution that will coexist with these technologies, not just hope there will be "safe zones".  Figure out how to have portable low-power usage systems that are intelligent enough to tune themselves out of the way of a problem that pops up after a shoot has started.  Eventually the entire UHF spectrum will be in play for this usage--including current over-the-air TV channels, the licenses for which, I predict, will all end up being bought back or renegotiated.  Resistance is futile, although I appreciate that litigation and bureaucratic inertia have bought me some extra years on gear I already have.

phil p

[studiomprd]

" I'll say it again: the makers of wireless mic equipment need to find a technical solution  "

as I read this, you are implying that they are not doing all they can to come up with solutions, and that would be just plain wrong.

http://www.shure.com/americas/products/wireless-systems/pgxd-systems/index.htm

Shure sells more wireless systems than all of "our usual suspects" combined! Thus they have a huge stake in trying out any possible solutions. Sure, (!), this one isn't the solution you, and the resy of "us" are waiting for, but it is one of the ideas being developed. 

Of course our usual suspects are just as concerned (in at least one case wireless microphone systems are just about their whole business) as Shure, and the other MI/SC makers of wireless like AT ( http://www.audio-technica.com/cms/wls_systems/ac51bb9cb7dd6883/index.html  and  http://www.audio-technica.com/cms/wls_systems/e7dd603ca6147a97/index.html )  and Sabine ( http://www.sabine.com/Pro_SWM7000_index.htm  and  http://www.sabine.com/Pro_SWM6000_index.htm )

[Philip Perkins]

" I'll say it again: the makers of wireless mic equipment need to find a technical solution  "

as I read this, you are implying that they are not doing all they can to come up with solutions, and that would be just plain wrong.

http://www.shure.com/americas/products/wireless-systems/pgxd-systems/index.htm

Shure sells more wireless systems than all of "our usual suspects" combined! Thus they have a huge stake in trying out any possible solutions. Sure, (!), this one isn't the solution you, and the resy of "us" are waiting for, but it is one of the ideas being developed. 

Of course our usual suspects are just as concerned (in at least one case wireless microphone systems are just about their whole business) as Shure, and the other MI/SC makers of wireless like AT ( http://www.audio-technica.com/cms/wls_systems/ac51bb9cb7dd6883/index.html  and  http://www.audio-technica.com/cms/wls_systems/e7dd603ca6147a97/index.html )  and Sabine ( http://www.sabine.com/Pro_SWM7000_index.htm  and  http://www.sabine.com/Pro_SWM6000_index.htm )

Slow down Mr. Senator--that implication is in your mind only.  I saying what I think needs to happen--all the pro wireless people would be fools to not be thinking of a solution to this issue, and I don't think they are fools.  I'm saying that any remedies that include

things like that bogus spectrum sensing, "safe" zones or any sort of voluntary avoidance of freqs we might be using are rear-guard actions only--they won't solve the problem and will either be overwhelmed or ignored sooner or later.  The technology we use has to change, somehow; to adapt.  The choices we must make right now about block selection have just been somewhat randomized--I don't see a good way (and an affordable way) to be ready for the interference caused by these sorts of wifi devices.  I just hope that they stay up once they are deployed, and don't shut down when not in use (so we can more easily find them).

phil p

[studiomprd]

"  I just hope that they stay up once they are deployed, and don't shut down when not in use  "

alas, that does not seem to be the case...

[RPSharman]

Using rechargeable batteries, I try leave my boom on the entire time.  Perhaps this will prevent a "seeking" device to stay away from "my" frequency.  Perhaps it'd be wise, once we find an open set of frequencies in a particular area, to leave the wireless cooking at least for the duration of a scene, until we know for sure we won't need to put them on any actors.  Maybe this will keep these consumer devices from moving into a particular frequency for the length of time we need to complete the scene.

[hemmerlinj]

What I really don't understand is this need to go wireless for all of the consumer toys.  Why is it that necessary to be able to have extremely high bandwidth internet on your phone.  If you're out doing something you don't need to bother with your stupid phone or whatever it is you're using.  Simple email and cell phone service is fine.

A major aspect of how we make our money is being bull dozed because some douche bag wants to play World of Warcraft on his Ipad in the middle of central park.  Seriously, we have all of these devices that distract us from the fact that we're walking down a street.  Next thing you know we're a puddle of blood and guts stuck in the wheel of a bus because we didn't look both ways before crossing the street. 

The fact that there are laws being out into affect to regulate the usage of such devices in our cars is sign that it's already too much.  Don't get me wrong.  I love my blackberry, but I use it as a tool.  A tool to communicate with clients for work, and then friends and family.  I don't need anything more than what it already can do.  Most people don't really need what most of these devices can do.  They're toys for most people.  Toys that they get addicted to.

Jason Hemmerlin

[RPSharman]

Next thing you know we're a puddle of blood and guts stuck in the wheel of a bus because we didn't look both ways before crossing the street. 

Jason Hemmerlin

It's about time something comes along to thin the herd.

[studiomprd]

"  leave the wireless cooking "

been doing this for years in various situation; I call it "camping out" on clear frequencies, and it seems to work at those events with lots of press, among other situations.

" What I really don't understand is this need to go wireless for all of the consumer toys. "

because!

" A major aspect of how we make our money is being bull dozed because ... "

yep!

" but I use it as a tool.  A tool to communicate with clients for work, and then friends and family.  I don't need anything more than what it already can do.  Most people don't really need what most of these devices can do.  They're toys for most people.  Toys that they get addicted to. "

so??

get over it...

[Philip Perkins]

Using rechargeable batteries, I try leave my boom on the entire time.  Perhaps this will prevent a "seeking" device to stay away from "my" frequency.  Perhaps it'd be wise, once we find an open set of frequencies in a particular area, to leave the wireless cooking at least for the duration of a scene, until we know for sure we won't need to put them on any actors.  Maybe this will keep these consumer devices from moving into a particular frequency for the length of time we need to complete the scene.

I kind of doubt this will continue to work.  The new idea is to blanket large areas w/ WiFi coverage in the UHF band all the time, and any non-licensed TV channel is fair game, pretty much.  In other words, they'll probably already be transmitting when you get there--as w/ the OP's situation.

phil p

[studiomprd]

In addition to all the manufacturers,  the FCC will be on the floor at NAB!!

(and they were also there for CES!)

[studiomprd]

" The Obama administration will make an economic case on Wednesday for moving ahead with a controversial auction of broadcast airwaves, even as some analysts argue that AT&T’s proposed merger with T-Mobile throws a wrench into the plan.  Some analysts suggest that the proposed merger of AT&T and T-Mobile would reduce concerns of a so-called spectrum crisis and delay any legislative action on Obama administration plans to auction off broadcast spectrum. Stifel Nicolaus analyst Rebecca Arbogast said, "If these two companies can satisfy much of their spectrum needs by joining forces, it would reduce some of the demand for new spectrum and possibly lower auction revenue estimates." The Obama administration will make an economic case on Wednesday for moving ahead with a controversial auction of broadcast airwaves, even as some analysts argue that AT&T’s proposed merger with T-Mobile throws a wrench into the plan.  There are several steps to the auction process. An administration official estimated it could take at least three years before any radio waves are put on the block. And broadcasters are lobbying lawmakers for legislation that protects their interests. They want to be ensured they aren't forced to give up airwaves or move to junk channels on low-quality bands. "

http://www.washingtonpost.com/business/economy/white-house-pushing-ahead-with-airwaves-auction-plan/2011/04/05/AFbMgxlC_story.html

[studiomprd]

here is a pertinent update:

" This was a demo TVBD operating from 650-698MHz brought to the CTIA show

by Spectrum Bridge, one of the database administrator candidates (and not

one of the ones friendly to incumbent Part 74 users). This box was one of

Airspan's existing products with a down converter. The Spectrum Bridge guy

on site was Philip Hill. If this unit was not referencing a geo-location

database for available channels, and one that Part 74 users could access to

ascertain all TV channels unavailable to TVBDs, and did not have an

experimental STA, it was in violation of FCC rules. Further, according to

Spectrum Bridges's own "Show My White Space" application, there are no

channels available to TVBDs in Orlando. In short, they were almost certainly

operating illegally. Why didn't you seek out the on site "official" CTIA

show frequency coordinator from Commsearch?

Henry Cohen

Production Radio Rentals "

and then:

" There's much more to this very troubling event !

I can inform the group that all appropriate notifications to the respective FCC

divisions and broadcast trade associations were made and that this event remains

an on-going investigation and is of intense interest to many people....

stay-tuned.

All professional wireless users are strongly encouraged to closely follow White

Space issues as they continue to un-fold.

KP  "

[studiomprd]

As I keep noting,  we (production sound mixers) are the mosquitoes in this situation:

" The Federal Communications Commission has a solution: reclaim airwaves from “inefficient“ users — specifically, television broadcasters — and auction them off to the highest bidder "

http://www.nytimes.com/2011/04/22/business/media/22spectrum.html?nl=todaysheadlines&emc=tha25

[studiomprd]

and, BTW, the pain is being spread all around, as HAM radio bands are also under attack

(H.R. 607)

[Philip Perkins]

Everything about wireless everything is going to change....

phil p

[geordi]

Everything about wireless everything is going to change....

phil p

True... Which begs the question: For those of us operating Part 15 devices (that's everything we use) with exceedingly low power outputs (less than 250mw) where the sum-total range of our field of influence is less than 1000' of detectable signal... Other than the moral implications of operating a transient "pirate radio" transmitter... Who's to know what we-the-mosquitos are doing besides us alone?

Part 15 specifically states that we cannot cause harmful interference to anything else, and assuming that the gear we have hasn't been modified in some way, it won't. At the same time, our power levels are so low as to be jammed off the air by just about anything else, so the chance of US causing interference with something operating at a MUCH higher output power is minuscule to the extreme. Even some consumer gear like a CB radio operates at 4 WATTS which is about 2000 times stronger than our microphones. Should a perfect atmospheric inversion allow that 26mHz frequency to cause a harmonic against a microphone frequency (call it VHF for this example) that microphone won't have a prayer of cutting through the jamming from the CB power.

Its the same with TV stations now, that we have to steer around, or the coming-someday internet providers. We won't be noticed by them, but we will have to steer around their blocks of noise to find a hole for our microphones. Technically, according to my own letter-of-the-law reading, ANY wireless microphone on ANY block is capable of being a "pirate radio" transmitter unless the operator has been registered and licensed, and the location of that transmitter is known to the FCC.

Are we really going to do that for all our out-on-location shoots? Of course not. So in that respect, we are already in the gray area and have been left alone. Where is the harm that until such time as we cannot operate (due to the start-up of the internet transmissions) in Block 27, we continue to use gear we already have? Part 15 says WE will be the ones to suffer interference, not anyone else... So why not have at it for as long as we can?

[studiomprd]

" The so-called "spectrum crisis" put forth by the Obama administration, FCC and wireless providers doesn't exist, according to a new report commissioned by the NAB. The justification for the alleged spectrum shortage is "underwhelming," given that there has been "insufficient analysis and reliance on faulty information" to develop the FCC's National Broadband Plan. The study also identifies ways to maximize spectrum, including better network technology, without taking it away from broadcasters.  "

http://r.smartbrief.com/resp/cSxuCAbduYdAauuYfDanccfCptFo?format=standard

[Philip Perkins]

" The so-called "spectrum crisis" put forth by the Obama administration, FCC and wireless providers doesn't exist, according to a new report commissioned by the NAB. The justification for the alleged spectrum shortage is "underwhelming," given that there has been "insufficient analysis and reliance on faulty information" to develop the FCC's National Broadband Plan. The study also identifies ways to maximize spectrum, including better network technology, without taking it away from broadcasters.  "

http://r.smartbrief.com/resp/cSxuCAbduYdAauuYfDanccfCptFo?format=standard

Yeah, well this comes from the broadcasters, and of course the broadband people have their science etc which is contradictory.  They also have a lot more money.  See where this is going?  No, we won't be any trouble to the new users of UHF as they blow us off the air.

phil p

[studiomprd]

" As debate swirls over whether there actually is a spectrum crunch, Congress doesn't seem to be in a hurry to approve legislation authorizing voluntary incentive auctions of broadcast spectrum. Broadcasters are concerned that those who opt out of a spectrum sale will be able to stay in business. "We demand that they be held harmless," said NAB President Gordon Smith. "Held harmless financially. Held harmless in terms of their signal strength and reach. Held harmless in terms of their opportunity to innovate and provide technological offerings of the future like mobile, multicasting and 3D.

http://r.smartbrief.com/resp/cSAECAbduYdAsTaIfDanccfCtSjx?format=standard

[WhyOne]

So. What to do.... First and foremost - If you read "Part 15" you will find that it does not describe the work we do. Part 15 allows the manufacturers to sell the stuff to unlicensed users who use them for different purposes:

*Note: These pieces have been excerpted from the FCC Regs, as pertain to us.

PART 15_RADIO FREQUENCY DEVICES--Table of Contents

                            Subpart A_General

Sec. 15.3  Definitions.

    (a) Auditory assistance device. An intentional radiator used to

provide auditory assistance to a handicapped person or persons. Such a

device may be used for auricular training in an education institution,

for auditory assistance at places of public gatherings, such as a

church, theater, or auditorium, and for auditory assistance to

handicapped individuals, only, in other locations.

Sec. 15.242  Operation in the bands 174-216 MHz and 470-668 MHz.

    (a) The marketing and operation of intentional radiators under the

provisions of this section is restricted to biomedical telemetry devices

employed solely on the premises of health care facilities.

Our use of these bands actually falls under Part 74:

PART 74_EXPERIMENTAL RADIO, AUXILIARY, SPECIAL BROADCAST AND OTHER PROGRAM DISTRIBUTIONAL SERVICES

•  Sec. 74.532 Licensing requirements. Aural auxiliary stations licensed to low power FM stations will be assigned on a secondary basis; i.e., subject to the condition that no harmful interference is caused to other aural auxiliary stations assigned to radio broadcast stations. Auxiliary stations licensed to low power FM stations must accept any interference caused by stations having primary use of aural auxiliary frequencies.

•  Sec. 74.801 Definitions.

•  Motion picture producer. Motion picture producer refers to a person or organization engaged in the production or filming of motion pictures.

•  Television program producer. Television program producer refers to a person or organization engaged in the production of television programs.

•  Wireless assist video device. An auxiliary station authorized and operated by motion picture and television program producers pursuant to the provisions of this subpart. These stations are intended to transmit over distances of approximately 300 meters for use as an aid in composing camera shots on motion picture and television sets.

•  Sec. 74.832 Licensing requirements and procedures. (a) A license authorizing operation of one or more low power auxiliary stations will be issued only to the following:

•  (4) Motion picture producers as defined in Sec. 74.801.

•  (5) Television program producers as defined in Sec. 74.801

For video assist it is a bit more complicated.

Sec. 74.870  Wireless video assist devices.

    Television broadcast auxiliary licensees and motion picture and

television producers, as defined in Sec. 74.801 may operate wireless

video assist devices on a non-interference basis on VHF and UHF

television channels to assist with production activities.

    (a) The use of wireless video assist devices must comply with all

provisions of this subpart, except as indicated in paragraphs (

through (i) of this section.

    ( Wireless video assist devices may only be used for scheduled

productions. They may not be used to produce live events and may not be

used for electronic news gathering purposes.

    © Wireless video assist devices may operate with a bandwidth not

to exceed 6 MHz on frequencies in the bands 180-210 MHz (TV channels 8-

12) and 470-698 MHz (TV channels 14-51) subject to the following

restrictions:

    (1) The bandwidth may only occupy a single TV channel.

    (2) Operation is prohibited within the 608-614 MHz (TV channel 37)

band.

    (3) Operation is prohibited within 129 km of a television

broadcasting station, including Class A television stations, low power

television stations and translator stations.

    (d) Wireless video assist devices are limited to a maximum of 250

milliwatts ERP and must limit power to that necessary to reliably

receive a signal at a distance of 300 meters. Wireless video assist

devices must comply with the emission limitations of Sec. 74.637.

    (e) The antenna of a wireless video assist device must be attached

to the transmitter either permanently, or by means of a unique connector

designed to allow replacement of authorized antennas but prevent the use

of unauthorized antennas. When transmitting, the antenna must not be

more that 10 meters above ground level.

    (f)(1) A license for a wireless video assist device will authorize

the license holder to use all frequencies available for wireless video

assist devices, subject to the limitations specified in this section.

    (2) Licensees may operate as many wireless video assist devices as

necessary, subject to the notification procedures of this section.

    (g) Notification procedure. Prior to the commencement of

transmitting, licensees must notify the local broadcasting coordinator

of their intent to transmit. If there is no local coordinator in the

intended area of operation, licensees must notify all adjacent channel

TV stations within 161 km (100 mi) of the proposed operating area.

My recommendation is that all production mixers that hold US citizenship obtain Low Power Auxiliary Broadcast Licenses under Part 74. Notify the Area Frequency Coordinator of the FCC where you intend to operate (which frequencies) , and these freqs will be off limits to White Space Devices in the area. Hopefully, the FCC will enforce their regs. Also, the much enlarged number of investigators for the FCC, when they visit your set, will not be able to fine you $11,000 per channel (max of $82,000) and threaten you with a year in Federal prison.

On the up side, if we all get licensed, the next time allocations of the RF are being discussed, we will have the combined voice of several hundred licensed operators who derive their livelihood, and provide content...

Along with Bill Ruck (a wonderful engineer in San Francisco), Tim Holly (Frequency Coordinator at CBS Radford in LA) I have been trying to put together a program facilitating the licensing process. Jeff Wexler has agreed to donate a little space within the Discussion Group to help get the word out - more to come soon.

Jay Patterson, CAS aka WQNJ498 Low Power Auxiliary Broadcast License

[studiomprd]

I know I have mentioned that we production sound folks are just a small niche...

here is a recent article:

Given the recent and ongoing changes in FCC wireless system legislation, those looking to buy any quantity of wireless systems would be well-served to do their due diligence prior to making a purchase and familiarize themselves with the current rules regarding wireless system usage.

http://svconline.com/microphones/products/wireless_mics_tech_showcase/index.html